There have been many whispers and rumors among the solid waste industry about the future changes to the NYSDEC Part 360 regulations. We have an update!
If you are unaware, the New York State Department of Environmental Conservation released new regulations on September 20, 2017. These regulations went into effect on November 4, 2017. These changes caused major changes and updates to status of compliance among the Solid Waste Industry. Many facilities that were once registered, now require a permit to continue operations. Similarly with exempt facilities, many now require registrations, and they might have never filed a piece of paperwork for the NYSDEC before now.
For more information, click here for our Part 360 Service Page.
Yes. There is a lawsuit against the NYSDEC about these changes and the impact to the industry. New York Construction Materials Association (NYCMA) filed a lawsuit against the NYSDEC in regards to these new regulations. The result? A monthly meeting between NYCMA and the NYSDEC to discuss the meanings, understandings, and purpose of these new regulations put into place.
There has been rumors going around the industry about the NYSDEC rewriting the regulations and releasing them very soon. After NYCMA’s most recent meeting with the NYSDEC, the NYSDEC hopes to have the revised regulations by June 2019, and final implementation in December 2019.
Yes, June 2019. AND, you are required to complete your permit registration by May 3, 2019. So, if you and your company are waiting for the revised regulations to come out before you make any moves on complying with the new Part 360 regulations, you will not be in compliance for AT LEAST 2 months, and run the risk of the NYSDEC giving your company a notice of violation. They have the power to close your facility May 4, 2019 if you are not in compliance.
If your Solid Waste Facility is not in compliance or if you are not sure if your company is in compliance, contact our Solid Waste Experts on staff. We will be able to assess your facility and make sure the NYSDEC will not be giving you a violation on May 4, 2019.